California’s Evolving Ultra-Processed Food Regulations: A Challenge or an Opportunity for K-Food?

California’s AB 2244 gains bipartisan support, advancing a proposed state-recognized certification system

Korean food manufacturers face growing pressure to transition from complex ingredient formulations to clean-label products

Product reformulation may be essential to meeting certification standards, while traditional Korean foods could gain a competitive advantage

Jay Lee, President, J&B Food Consulting

California, long regarded as a regulatory trendsetter in the U.S. food industry, has taken another significant step toward addressing ultra-processed foods.

The California Legislature recently passed AB 2244, the proposed Non-Ultraprocessed Certified legislation, with bipartisan support. The bill aims to increase consumer awareness of ultra-processed foods (UPFs) and expand access to products that meet clean-label standards. Following legislative approval, the measure was awaiting Governor Gavin Newsom’s signature.

This development follows California’s earlier efforts to regulate food additives. Through the California Food Safety Act (AB 418), the state prohibited four specific food additives, including Red Dye No. 3 and brominated vegetable oil. California also enacted AB 2316, restricting certain artificial food dyes in foods served at public schools.

Now, the state is moving beyond restrictions on individual additives toward a broader regulatory framework addressing ultra-processed food certification and retail product visibility.

A New Direction in Food Certification

AB 2244 proposes a framework for recognizing foods that meet specified non-ultra-processed criteria.

Under the proposed system, qualifying products could receive a “Non-Ultraprocessed Certified” designation through a certification framework involving oversight by the California Department of Public Health (CDPH).

Similar in concept to familiar programs such as USDA Organic, the proposed certification would help consumers identify products that meet defined standards concerning ingredients and processing.

Products containing certain additives, such as artificial colors, flavor enhancers, non-sugar sweeteners, emulsifiers, and thickeners, may face additional scrutiny depending on the final certification criteria.

The broader objective is to provide consumers with clearer information about food processing and ingredient composition while encouraging manufacturers to develop products with simpler formulations.

The Challenge for Korean Food Manufacturers

For Korean food manufacturers, this development raises an important concern.

The Korean processed food industry has traditionally relied on a wide variety of food additives, flavor enhancers, and compound ingredients to optimize taste, texture, shelf life, and product consistency.

Complex seasoning blends, prepared sauces, stabilizers, and other multi-component ingredients are commonly used across many Korean processed food categories.

As a result, ingredient declarations can become lengthy and complicated, sometimes containing numerous sub-ingredients within a single finished product.

While these ingredients may be legally permitted under applicable FDA regulations, regulatory compliance alone does not necessarily mean that a product will qualify for a voluntary Non-UPF certification.

This distinction could become increasingly important as U.S. consumers and retailers place greater emphasis on ingredient simplicity and processing methods.

If K-food is to move beyond its reputation for bold flavors and trendy international cuisine and establish itself more firmly within the mainstream healthy food market, a strategic shift toward clean-label product development may be necessary.

Clean-Label Reformulation: A Strategic Priority

For Korean exporters, the proposed Non-UPF certification framework could represent more than a regulatory challenge.

It may also create an opportunity to reposition Korean products as premium, health-conscious food options in the U.S. market.

Manufacturers should begin by reviewing ingredients commonly used in export products, including:

Artificial flavors and colors

Thickeners such as xanthan gum and carrageenan

Emulsifiers and stabilizers

Compound seasoning sauces and flavor blends

Other additives used to enhance texture, appearance, or shelf life

The goal should not simply be to eliminate ingredients indiscriminately, but to evaluate whether formulations can be simplified while maintaining product safety, quality, stability, and consumer acceptance.

Product reformulation may involve reducing unnecessary additives, replacing certain ingredients with suitable alternatives, simplifying compound ingredient systems, or adjusting manufacturing processes.

Companies that begin this evaluation early may be better positioned to respond as certification standards, retailer expectations, and consumer preferences continue to evolve.

Traditional Korean Foods May Have a Competitive Advantage

One of K-food’s greatest strengths lies in its traditional food heritage.

Products such as kimchi, traditional fermented soybean pastes, minimally processed snacks, and grain-based beverages may offer opportunities for clean-label positioning when manufactured with appropriate ingredients and processing methods.

These categories often have strong connections to traditional preparation methods, recognizable ingredients, and established culinary practices.

However, certification eligibility would still depend on the specific product formulation, manufacturing process, and applicable certification criteria.

For manufacturers able to meet those standards, a recognized Non-UPF designation could become a valuable marketing and retail differentiation tool.

It could also help Korean brands communicate product quality and ingredient transparency to American consumers who may be unfamiliar with traditional Korean foods.

If major retailers increasingly emphasize certified products through premium displays or dedicated merchandising programs, early certification could provide an additional competitive advantage.

Turning Regulatory Pressure into Market Opportunity

California’s evolving approach to ultra-processed foods sends a clear signal to the food industry.

Manufacturers that rely heavily on complex additive systems may face increasing pressure to reassess their formulations and product positioning.

At the same time, companies willing to invest in clean-label innovation, ingredient transparency, and product reformulation may discover new opportunities in the U.S. premium food market.

For Korean food exporters, this shift should not be viewed solely as another regulatory obstacle.

Instead, it offers an opportunity to strengthen the global identity of K-food—not merely as flavorful and innovative cuisine, but as a category capable of delivering quality, transparency, and products aligned with evolving consumer expectations.

Ultimately, California’s ultra-processed food initiatives may serve as both a warning and an opportunity.

For Korean manufacturers prepared to adapt, the transition toward clean-label products could become a foundation for redefining K-food as a competitive force in the global health-conscious food market.

Machine translated

Feel free to contact us

jay@jnbfoodconsulting.com or 714-873-5566